I have served on the Arlington County Gifted Services Advisory Committee for five years (four as Chair or co-Chair) and am the parent of a seventh-grader and a third-grader, each of whom has been identified as gifted.  I am also a member of the Arlington Coalition for Challenging Education, a advocacy group of Arlington parents, citizens, and teachers organized to increase the level of challenge in public schools.

I am focusing my comments on the provision of the proposed regulations that would eliminate review of local five-year plans by the Virginia Department of Education.  In its place, the proposed regulations rely on local advisory committees to annually review the plans of their school divisions and determine whether their goals are being met.  In addition, the proposed regulations charge local School Boards with approving the plan on an annual basis.  I believe this change would injure the qualify of gifted education across the Commonwealth, and I urge that this change be dropped.

While the membership of our local advisory committee has fluctuated over the years, our committee is small and is made up of parents, interested citizens, and occasionally high school students.  I admire my fellow members, but most of us are not experts on gifted education, teaching, or school administration.  Most of us joined out of interest in learning more about Arlington gifted services and because we had specific concerns relating to the education of our children that we thought might be worth raising more broadly for the School Board's consideration.  We meet approximately ten times per year, for two hours or so, one evening a month.  We are School Board appointees who report to the School Board annually and make recommendations to the School Board biannually.  Our recommendations focus on one or two key issues that are of particular interest to the committee.  More often than not, the School Board listens respectfully and declines to implement our recommendations, although we have had occasional successes.  In past years, for example, we have recommended increasing the staffing levels of resource teachers for the gifted and urged the school system to explore assessment systems that measure the individual longitudinal growth of students.  This year, our focus is also on Advanced Placement courses in high school and their effect on students' workload and the availability of non-college level honors classes in high school.

I believe the work of the local advisory committee is worthwhile and that it has contributed to important and beneficial changes in gifted instruction in Arlington.  I do not pretend, however, that our committee is qualified to undertake a comprehensive review and assessment of the school system's gifted education plan on an annual basis.  As a member of the advisory committee, I was invited and did participate in focus groups that reviewed the gifted services department's draft five-year plan.  Although I had comments on certain areas, it was obvious that I lacked the expertise and knowledge to contribute meaningfully to the review of many other aspects of the plan. 

If the Virginia Department of Education cedes its historical role in reviewing five-year plans and asks our small local advisory committee to conduct such reviews annually, the quality of such reviews will certainly plummet. 

The proposed regulations' substitution of annual School Board approval for Virginia Department of Education approval hardly improves matters.  Our School Board members are fine individuals, but they are politicians, not education professionals.  Their election campaigns focus primarily on specific high-profile issues: boundary changes, reducing the achievement gap, capital improvement projects, opening school facilities for community use, etc.  Almost by definition, parents of gifted students are in a minority of the electorate.  Our issues are usually not the popular ones and (with a few notable exceptions) rarely get the sustained attention of School Board members.  Our political clout is small.  While the knowledge of the School Board members on school system matters far exceeds that of the members of our local advisory committee members, the local School Board should not be the body charged with approval of gited services plans.  The plans -- and their compliance with regulations and best practices for gifted education -- should not depend on the review of a local political body with no specific expertise in the requirements for the plans. 

By contrast, the Virginia Department of Education has specific expertise in gifted education.  Because it reviews not just one plan a year, but rather the plans of all the school systems' gifted education departments on a five-year cycle, it can offer objectivity and insight that neither the local School Boards nor the local advisory committees can provide.  The risk of wide variation across school systems, based on the idiosyncratic preferences and political leanings of the local School Boards, is also materially lessened by the Virginia Department of Education's role in the approval process.

In addition to the problem of which body is charged with plan approval, the change in timing from a five-year cycyle to an annual cycyle is also harmful.  Arlington County is fortunate to have a remarkably capable, experienced, dedicated, and talented Gifted Services Supervisor.  Nonetheless, the switch from a five-year cycle to an annual review cycle would tax even her ability to plan meaningful changes, which often take several years to conceive and implement.  This change in the proposed regulations is virtually an invitation for overworked school systems to comply by changing the cover sheet on their local plans once a year, rather than engaging in the thoughtful and time-intensive process characteristic of the five-year plans. 

Even if funding for the peer-review associated with the five-year plans is unavailable, the regulations can nonetheless encourage the peer review process.  It can be included as a recommended element of the five-year process, with the proviso that, when state funding is available, it will be required.  My expectation is that local school systems so value the insight provided by the peer-review process that most may use some funds from their own budgets to participate voluntarily if the regulations provide the framework for doing so.

I share many of the concerns on other aspects of the proposed regulations that have been expressed by others who have submitted comments, but I will limit my own comments to this topic.  Thank you for allowing this opportunity for the stakeholders to offer their views before issuance of the final regulations.